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Extended Producer Responsibility (EPR) for Non-Ferrous Metal Scrap

Introduction

Extended Producer Responsibility (EPR) is an environmental strategy designed to make producers accountable for managing the full lifecycle of their products, including post-consumer waste. In India, a pivotal advancement in this area has been the establishment of EPR regulations specifically targeting scrap from non-ferrous metals like aluminum, copper, and zinc. This policy is intended to boost recycling rates, lessen environmental impact, and encourage sustainable practices in the metal sector.

Background

On August 14, 2024, India’s Ministry of Environment, Forest, and Climate Change (MoEFCC) issued a draft notification introducing EPR guidelines within the Hazardous and Other Wastes (Management and Transboundary Movement) Second Amendment Rules, 2024. This draft framework aims to create a structured approach for handling non-ferrous metal waste and foster growth in the recycling sector, addressing pollution concerns and resource limitations.

Scope of EPR

The EPR framework encompasses a variety of products made from non-ferrous metals, including:

  • Cans for Beverages, aerosols and other such product
  • Packaging Foils for food, pharma and other such product
  • Doors, windows, shutters
  • Aluminium composite panel (ACP)
  • Aluminium partitioning, grills and other such product
  • Utensils (Cookware, canisters, storage and other such product)
  • Furniture tables, chairs, benches, ladders etc. including doorknobs, handles, hardwares
  • Roofing & Ceiling sheets
  • Motors, pumps, alternators and other such product
  • Conductor cables & Wires, strips
  • Sanitary ware & fittings
  • Electrical fittings
  • Aluminium Alloy Bicycle
  • Transformer
  • Electric Generator sets
  • Centralized air conditioning plants
  • Apparel products e.g. Belt Buckles, Zip, Shoes
  • Toys

Under these regulations, producers are responsible for ensuring that these products are collected and recycled at the end of their lifecycle.

Applicability

The following entities must register with the Central Pollution Control Board through the designated portal:
(a) manufacturers;
(b) producers;
(c) collection agents;
(d) refurbishers; and
(e) recyclers.

Registration and Compliance To meet EPR requirements, manufacturers, producers, collection agents, refurbishers, and recyclers must register with the Central Pollution Control Board (CPCB). This registration is essential for monitoring compliance and purchasing EPR certificates from registered recyclers.

Key Registration Requirements:

  • Producers of non-ferrous metal products must register if they manufacture or sell products under their brand.
  • Registration fees and annual maintenance charges may apply.

EPR Certificates Producers fulfill their EPR obligations by purchasing EPR certificates from certified recyclers. These certificates confirm that recycling targets have been met, and they remain valid for two years from the end of the financial year in which they were issued.

Recycling Targets The draft regulations set forth recycling targets for the upcoming years:

  • 2025-2026: 10%
  • 2026-2027: 10%
  • 2027-2028: 30%
  • 2028-2029: 30%
  • 2029-2030: 50%
  • 2030-2031: 50%
  • 2031-2032 onward: 75%

These targets are based on the typical lifespan of the products.

Advantages of EPR for Non-Ferrous Metals

Implementing EPR for non-ferrous metals offers several benefits:

  • Resource Conservation: Increased recycling reduces dependency on new materials, minimizing environmental impact from mining.
  • Waste Reduction: Effective waste management lessens landfill usage and improves the recovery of non-ferrous metals.
  • Environmental Protection: The framework promotes cleaner production practices and environmentally friendly technologies.
  • Economic Efficiency: Improved recycling processes lower costs and boost competitiveness within the recycling sector.
  • Consumer Awareness: Educating the public on recycling fosters responsible consumption habits.

Future Prospects

The draft regulations are open for public consultation until October 14, 2024. Feedback will be reviewed before finalizing the rules, which are scheduled to take effect on April 1, 2025. These regulations are expected to bring substantial change to India’s non-ferrous metals industry by establishing a more organized recycling system and generating new job opportunities.

Conclusion

India’s adoption of an EPR framework for non-ferrous metals marks a significant step in advancing sustainable waste management. This approach addresses environmental challenges linked to metal production and disposal while fostering a more eco-friendly and organized recycling ecosystem.

FAQs

  1. How does the EPR framework for non-ferrous metals compare to that for E-waste?

The EPR frameworks for non-ferrous metals and E-waste in India both promote responsible recycling, but differ in scope and approach due to the distinct materials involved.

  • Scope: EPR for non-ferrous metals covers items like aluminum and copper products, while E-waste focuses on electronics such as computers and mobile phones.
  • Regulation: Non-ferrous metals fall under Hazardous Waste rules, whereas E-waste has dedicated management rules due to its hazardous components.
  • Targets: Non-ferrous metal targets begin at 10% recycling by 2025, reaching 75% by 2031. E-waste has more immediate targets to address high turnover rates.
  • Impact: EPR for metals aims to conserve natural resources, while E-waste regulations focus on safely managing toxic waste and recovering valuable materials.

Both frameworks advance sustainable practices, but each tailors its approach to the unique challenges of its industry.

2. What are the specific EPR obligations for importers of non-ferrous metals?

Importers of non-ferrous metals under India’s EPR framework must meet specific obligations:

  1. Registration: Register with the Central Pollution Control Board (CPCB) to track compliance.
  2. EPR Certificates: Purchase EPR certificates from registered recyclers to fulfill recycling obligations.
  3. Recycling Targets: Achieve phased recycling targets, starting at 10% by 2025-2026 and reaching 75% by 2031.
  4. Reporting: Submit annual compliance reports to CPCB to document progress in meeting EPR requirements.

These obligations ensure that importers contribute to sustainable recycling and resource conservation.

3. What are the registration requirements for producers under the EPR framework for non-ferrous metals?

Under the EPR framework for non-ferrous metals in India, producers must fulfill several registration requirements:

  1. Eligibility: Producers must register if they manufacture or sell products made from non-ferrous metals, such as aluminum, copper, and zinc.
  2. Registration with CPCB: Producers need to register with the Central Pollution Control Board (CPCB) to ensure compliance with EPR obligations. This registration facilitates tracking and monitoring of recycling efforts.
  3. Documentation: Producers must provide necessary documentation during registration, which may include details about the types of products manufactured, production quantities, and sales information.
  4. Fees: Registration may involve payment of registration fees and annual maintenance charges, as determined by the CPCB.
  5. Compliance with Targets: Registered producers are required to adhere to the recycling targets set forth in the EPR regulations, demonstrating their commitment to sustainable waste management practices.

By meeting these requirements, producers contribute to the responsible recycling of non-ferrous metal products and help mitigate environmental impacts.\

4. What are the key differences in the products covered under EPR for non-ferrous metals and E-waste?

The key differences in products covered under EPR for non-ferrous metals and E-waste lie in their types, complexity, regulatory focus, and lifecycle. Non-ferrous metals EPR covers items made from metals like aluminum and copper, such as beverage cans and construction materials, which typically have simpler compositions and longer life cycles. In contrast, E-waste includes electronic devices like computers and mobile phones, which contain a mix of materials, including hazardous substances, making their recycling more complex. The regulatory focus for non-ferrous metals emphasizes resource conservation and increasing recycling rates, while E-waste regulations prioritize managing hazardous waste and protecting public health. Additionally, electronic products have shorter life cycles and higher turnover rates, necessitating immediate recycling targets to address the rapid influx of waste.

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